Effective Jan 14, 2020


FOCUUS by Skywind Tech CY Ltd (“FOCUUS Skywind Tech CY Ltd”, “”, “we”, “us”, “our”) provides solutions for performance marketers. The Privacy Policy goal is to help you understand how Skywind Tech CY Ltd processes end user data on behalf of advertising networks, agencies, advertisers etc. who use the FOCUUS platform. It does not state the use practices or policies of our clients, of the websites or apps on which ads are shown, or of other parties. 

Skywind Tech CY Ltd and its clients care about the way end user data is collected, used, and shared. We are a "data processor" that collects and analyzes end user data at the specific request of our clients, the "data controllers". This Privacy Policy relates solely to our FOCUUS product.


AD SERVING is the process of delivering an ad to be shown in a web page or a mobile app.

ADVERTISERS Companies (apps, brands) that have a product or service they want to promote.

AD IDENTIFIERS are unique character strings associated with user devices that help monitor and measure user interactions with advertisements and apps. Examples of Ad Identifiers include IDFA (developed by Apple for the iPhone), Google Ad ID (developed by Google for Android), and Windows advertising ID (developed by Microsoft for Windows Phone). Each of these Ad Identifiers can be reset by the user.

AFFILIATE: An Affiliate is any website that displays advertisements on behalf of an Advertiser. The terms Affiliate and Publisher can be used interchangeably.

CLICKS refers to when a User “clicks” on the advertisement and goes to the offer’s page.

CLIENTS are FOCUUS clients, and may include individual employees of a FOCUUS client.

CONVERSIONS happen when the User completes the “offer” (e.g. making a purchase on an e-commerce site, installing a mobile app, filling out a survey, or doing some other action).

COOKIES are small text image files stored on your computer either temporarily or permanently to allow websites to recognize users and keep track of their preferences.

GEOGRAPHIC LOCATION DATA can either be precise (identifying the end user’s precise location) or imprecise (identifying the end user’s city or country). In FOCUUS we collect imprecise geographic data through IP address and/or wifi networks in the end user’s vicinity. We collect this data to help our clients provide more relevant advertisements and content, and to ensure we comply with country specific requirements.

IMPRESSIONS occur when a User sees an ad for an Advertiser on a Publisher’s site or app.

INVENTORY is website or mobile app traffic from Users that can be used for advertising

IP ADDRESS is a numerical label attached to any device that connects to the Internet. Most IP addresses are dynamic i.e. the device’s IP address changes and is not persistently tied to any one device. FOCUUS clients may opt to obfuscate IP addresses from certain jurisdiction.

NETWORK are brokers between mobile advertisers and publishers.

PIXEL TRACKING are website based and usually work in conjunction with cookies. They register when the User visits a particular page.

POSTBACKS are server-to-server communications between parties.

PUBLISHERS have Inventory and display ads on behalf of Advertisers.

USERS are end users, specifically individuals on websites or mobile apps that see and potentially interact with FOCUUS.

What Is FOCUUS And Why Do Our Clients Use Us?

FOCUUSPursuant to the Skywind Tech CY Ltd Data Pledge, our clients determine the data that they provide to and collect

is an advanced performance marketing platform, used by the top mobile and desktop networks to manage their online advertising relationships. Clients use FOCUUS to assess the effectiveness of their Affiliate and Publisher relationships – by measuring User clicks and conversions. through

FOCUUS. Clients’ use, collection, exportation, or any other use of end user Skywind Tech CY Ltd data, including the use of products and services, is governed by their own privacy policies and applicable laws, rules, or regulations. 

How Do Clients Collect User Information Using FOCUUS?

At the direction of our clients, who act as data controllers, FOCUUS collects the following types of information from Users to help clients optimize and measure their advertising network, affiliate and publisher relationships:

  • Ad Identifiers

  • IP address

  • Cookies

  • Pixel Tags

  • Imprecise Geographic Location Data derived from IP address and/or wifi networks.

FOCUUS also collects this information from employees of Clients who access information using their FOCUUS accounts to maintain up-to-date contact information.

Clients can also choose to view and measure information provided by other third-party sources in the FOCUUS platform. Those sources may include: Advertisers, Publishers, Affiliates, and other Networks and analytics partners. Affiliates may sign up with Advertisers through the FOCUUS platform or through their own customer Skywind Tech CY Ltd website. Affiliate information provided to our Advertisers will be used by for fraud prevention purposes and to fulfill contractual requirements with our Advertisers.

Clients own the data that they provide to and collect through the FOCUUS platform. When clients remove or export their data from the FOCUUS platform, their use of data is governed by their own privacy policies and applicable laws, rules, or regulations. FOCUUS Skywind Tech CY Ltd by serves as a data processor, acting at the direction of our data controller clients. Specific fields that likely contain personal data, such as IP address or device ID, may be obfuscated or blanked, respectively, by the FOCUUS client.


How Do Clients Use FOCUUS To Collect Information From Users?

Clients use FOCUUS for pixel or server postback tracking to collect information about Users. Pixel tracking (also called "cookie-based tracking" and "client-side tracking") methods store a FOCUUS session identifier in a user’s browser cookie on click. In postback tracking (also called "server-side tracking"), FOCUUS directly sends a session identifier to the advertiser on click. On conversion, the advertiser then communicates that identifier to FOCUUS for validation. FOCUUS also supports server-to-server measurement for some clients. With any of the mentioned methods, when an end user clicks on an advertisement, goes to a specific web page or mobile app action that a Client chooses to monitor, FOCUUS collects information from the User’s computer or device, including but not limited to IP and Ad Identifiers.

How Do Clients Use FOCUUS To Process Information From End Users?

·  Measuring the performance of ad campaigns

·  Measuring the performance of Affiliates, Publishers and Networks

·  Creating customized performance reports (for example, how well a particular advertisement is performing in a particular geographic region)

·  Determining when Users respond to ads

·  Ad Serving – FOCUUS uses data that does not personally identify users to target advertising for Clients. End users can be targeted by device type (OS, Make, Model) and imprecise geographic location (state and region).


What Information Does FOCUUS Collect From Clients?

Signing up as a Client requires setting up a FOCUUS account. To do this, we will need contact details – including mailing and/or billing address, email address, company name, and website URL. Clients will also need to provide a user name and password to set up a FOCUUS account. Please note that Skywind Tech CY Ltd treats all Client contact details as confidential business information that will only be used to service Client accounts and respond to Client, Affiliate or Publisher inquiries in accordance with a contractual agreement or applicable agreement by and between the parties.

In Which Instances Might FOCUUS Share End User Data With Third Parties?

FOCUUS may disclose end user data in the event we reasonably suspect fraudulent, malicious, or unlawful activity, or invalid traffic, or believe that we are legally required to do so. FOCUUS may also share anonymous aggregated data derived from the FOCUUS platform, including, for example, statistics about FOCUUS platform activity. Finally, we may transfer such data to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change.

Can Users Disable Cookie And Id Tracking Through FOCUUS?

End users can disable cookies in most internet browsers. Disabling cookies will not, however, stop receipt of all advertisements. If an end user would like to opt out of a particular ad network, publisher, or advertiser’s ads, they will need to contact those companies directly to inquire whether they have an opt-out option. 
End users can also disable collection of Ad Identifiers for targeted advertising by enabling the Limit Ad Tracking setting on their smartphone. End users can also reset the Ad Identifier altogether using their smartphone’s privacy settings. End users should also note that Skywind Tech CY Ltd collects information on behalf of its clients. To opt out, please see or contact the data controller directly. We will actively work with our clients to fulfill such requests as reasonable and required by law.

How Does Skywind Tech CY Ltd Adhere to GDPR Principles?

Skywind Tech CY Ltd serves as a data processor under the GDPR, and adheres to the principles and rules of the GDPR. Specifically, Skywind Tech CY Ltd implements privacy by design and default principles, ensures limited data retention protocols, adheres to incident response norms, allows for appropriate third party audits, ensures data is only transferred internationally with a lawful basis, only contracts with subprocessors with adequate written commitments to data processing, respects data subject rights, does not process sensitive personal data, and provides data processing agreements to all appropriate clients and partners.


Skywind Tech CY Ltd uses commercially reasonable efforts including a variety of security technologies and procedures to secure client and end user data from unauthorized access, use or disclosure.

What Happens If This Privacy Statement Is Changed?

FOCUUS may find it necessary to update this Privacy Policy from time to time. Please check this Privacy Policy, as any changes will be posted on this site.

Questions About This Privacy Policy?

If you have an unresolved privacy or data use concern that a Skywind Tech CY Ltd client or Skywind Tech CY Ltd has not addressed satisfactorily, please contact us at

Contact Information

If you have any questions regarding this Privacy Policy, or would like more information on our privacy practices, please contact us at or by mail at: 

Skywind Tech CY Ltd

Andrea Chaliou, 1, 1st floor, flat/office 1, Egkomi, 2408, Nicosia, Cyprus